Paul W. Raymond

Tax

Prepaid Interest Paid By Cash-Basis Taxpayers
In general, if you are a cash-basis taxpayer who prepays interest on a loan, you are not permitted to deduct all the interest in the year of payment. Under the Internal Revenue Code, you are required to capitalize the prepaid interest and deduct it as if you are an accrual-basis taxpayer. In other words, you cannot take a deduction for interest other than in the year in which it is due. The prepaid interest is allocated to the tax year in which the interest actually represents the cost of using the borrowed money. To allow a deduction of prepaid interest in the year of payment rather than in the year it is due would materially distort your income. More...
Expatriation Tax
The Internal Revenue Code imposes a tax on an individual who abandons his U.S. citizenship for the principal purpose of avoiding U.S. taxes. The expatriation tax applies to citizens who lose U.S. citizenship and to long-term permanent residents who terminate U.S. residency or who are treated as residents of another country pursuant to a treaty and who fail to waive treaty benefits. This tax may be assessed on U.S. source income for 10 years after the loss of the individual's citizenship or residency. More...
Individual Taxpayer Identification Numbers
The Internal Revenue Service issues Individual Taxpayer Identification Numbers (ITINs) to foreign nationals and other individuals who are required to have a U.S. taxpayer number but who are not eligible to receive a Social Security number. The issuance of ITINs helps individuals comply with federal tax laws and provides an efficient way for the IRS to process and account for tax returns and payments for those who are not eligible for Social Security numbers. More...
Taxpayer Assistance Orders
A taxpayer who believes that he or she is suffering, or is about to suffer, significant hardship as a result of the way in which the tax laws are being administered may be entitled to help from the Office of the National Taxpayer Advocate. The National Taxpayer Advocate has the authority to issue a taxpayer assistance order (TAO) upon the taxpayer's approved application. More...
SIMPLE 401k Retirement Plans
A section 401(k) plan is a type of deferred compensation plan that permits an employee to have his employer set aside a portion of his or her wages in the plan on a pre-tax basis. Upon making an election to participate in a 401(k) plan, the contributed wages are not subject to income tax withholding at the time of the deferral. Thus, they are not taxable wages at that time. However, they are subject to Social Security, Medicare, and federal unemployment taxes. More...

Areas of Practice

  • Federal and State Taxation Civil and Criminal Tax Litigation and Tax Controversy

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